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HomeMy WebLinkAbout13-5606 Supreme Co , ennsylvania COu fi,C011 i O ` leas For Prothonotary Use Only: C Vi10V r,S eet Docket No: Cu RLAN0 -�" County _ �D The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by lain or rules of court. Commencement of Action: S F1 Complaint 0 Writ of Summons 0 Petition Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiffs Name: Lead Defendant's Name: CITIMORTGAGE, INC. CHARLES L. 1301313, LYNNEA D. BOBB, NATHANIEL, T Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? 0 Yes El No (check one) Ox outside arbitration limits O N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? 0 Yes El No A Name of Plaintiff /Appellant's Attorney: POWERS, KIRN & JAVARDIAN, LLC Check here if you have no attorney (are a Self-Represented JPro Set Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle 0 Debt Collection: Other 0 Board of Elections Nuisance Dept. of Transportation 0 Premises Liability Statutory Appeal: Other S 0 Product Liability (does not include 0 Employment Dispute: E mass tort) 0 Slander/Libel/ Defamation Discrimination , C 0 Other: 0 Employment Dispute: Other 0 Zoning Board , 0 Other: I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Other: 0 Ejectment 0 Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation 0 Declaratory Judgment 0 Ground Rent Mandamus 0 Landlord/Tenant Dispute Non - Domestic Relations El Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental 0 Partition 0 Replevin 0 Legal 0 Quiet Title 0 Other: 0 Medical 0 Other: 0 Other Professional: Updated 1/1/2011 t POWERS, KIRN & JAVARDIAN, LLC r: r �- i , Gregory Javardian, Esquire Id No. 55669 �bt`'� rlCl rt�y Jill Manuel- Coughlin, Esquire Id No. 63252 R,� • �x Mary F. Kennedy, Esquire Id No. 77149 5 1E, ` A� °' 10 5 Meghan K. Boyle, Esquire Id No. 201661 M`13"E R L A NO CO Sean P. Mays, Esquire Id No. 307518 PENES Y°LVA N1 Richard J. Nalbandian, III, Esquire Id No. 312653 1310 Industrial Boulevard, Suite 101 Southampton, PA 18966 (215) 942 -2090 ATTORNEYS FOR PLAINTIFF CITIMORTGAGE, INC. COURT OF COMMON PLEAS 1000 TECHNOLOGY DRIVE O'FALLON, MO 63368 CIVIL DIVISION PLAINTIFF CUMBERLAND COUNTY VS. NO. 1 / 3 CHARLES L. BOBB COMPLAINT IN LYNNEA D. BOBB MORTGAGE FORECLOSURE NATHANIEL C. BOBB AMY R. BOBB 15 ROUND HILL ROAD CAMP HILL, PA 17011 DEFENDANTS CIVIL ACTION MORTGAGE FORECLOSURE 1. CitiMortgage, Inc. (hereinafter referred to as "Plaintiff') is a Corporation with a principal place of business in O'Fallon, Missouri. 2. Charles L. Bobb, Lynnea D. Bobb, Nathaniel C. Bobb and Amy R. Bobb (hereinafter referred to as "Defendants ") are adult individuals. 3. Upon information and belief, Charles L. Bobb is residing at 245 Birdie Lane, Etters, PA 17319. 4. Upon information and belief, Lynnea D. Bobb is residing at 245 Birdie Lane, Etters, PA 17319. 5. Upon information and belief, Nathaniel C. Bobb is residing at 15 Round Hill Road, Camp Hill, PA 17011. 6. Upon information and belief, Amy R. Bobb is residing at 15 Round Hill Road, Camp Hill, PA 17011. E, q� 633 t 7. Plaintiff brings this action to foreclose on the mortgage between Defendants and itself as Mortgagee by Assignment. The Mortgage, dated May 11, 2007, was recorded on May 15, 2007 in the Office of the Recorder of Deeds in Cumberland County in Mortgage Book 1992, Page 1006. Plaintiff is the Mortgagee by virtue of an Assignment of Mortgage recorded on July 29, 2012 in the Office of Recorder of Deeds in Cumberland County as Instrument 201219463. A copy of the Mortgage and Assignment of Mortgage are attached and made a part hereof as Exhibits `A' and `B'. 8. The Mortgage secures the indebtedness of a Note executed by Charles L. Bobb, Lynnea D. Bobb and Nathaniel C. Bobb on May 11, 2007 in the original principal amount of $199,424.00 payable to Plaintiff in monthly installments with an interest rate of 6.375 %. A copy of the Note is attached and made a part hereof as Exhibit `C'. 9. The land subject to the mortgage is 15 Round Hill Road, Camp Hill, PA 17011. A copy of the Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated herein. 10. The Defendants are the Record Owners of the mortgaged property located at 15 Round Hill Road, Camp Hill, PA 17011. 11. The Mortgage is now in default due to the failure of Defendants to make payments as they became due and owing. As a result of the default, the following amounts are due: Principal Balance $1 87,748.50 Interest to 09/01/2013 $20,945.61 Accumulated Late Charges $334.82 Inspections $270.00 Escrow Advance Balance $6,055.28 Interest on Escrow Advance $63.45 Unapplied Funds ($300.00) TOTAL $215,117.66 plus interest from 09/02/2013 at $32.7917 per day, costs of suit and attorney's fees. 12. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendants in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. r 13. If Defendants have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 14. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a defaulting mortgagor with a Notice of Intention to Foreclose ( "Act 6 Notice ") 41 P.S. Section 403. 15. The Notice of Intention to Foreclose was required and Plaintiff sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to the Defendants by regular and certified mail on March 23, 2012 and August 10, 2012. A copy of the Notice is attached and made a part hereof as Exhibit `D'. 16. The Mortgage is a Federal Housing Administration ( "FHA ") insured loan, and in accordance with 35 P.S. Section 1680.401c(a)(3) the notice provisions of 35 P.S. Section 1680.403c are not applicable and, therefore, Plaintiff was not required to send the Act 91 Notice of Homeowners' Emergency Mortgage Assistance. WHEREFORE, Plaintiff requests the court enter an in rem judgment against the Defendants, in the sum of $215,117.66, together with interest, costs, fees and charges collectible under the mortgage, including, but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgaged property. POWERS, KIRN & JAVARDIAN, LLC BY: J .1rgory Javardian, Esquir Id. No. 55669 Jill Manuel - Coughlin, Esquire Id. No. 63252 ❑ Mary F. Kennedy, Esquire Id. No. 77149 ❑ Meghan K. Boyle, Esquire Id. No. 201661 ❑ Sean P. Mays, Esquire Id. No. 307518 ❑ Richard J. Nalbandian, III, Esquire Id. No. 312653 Attorneys for Plaintiff s POWERS, KIRN & JAVARDIAN, LLC Gregory Javardian, Esquire Id No. 55669 Jill Manuel - Coughlin, Esquire Id No. 63252 Mary F. Kennedy, Esquire Id No. 77149 Meghan K. Boyle, Esquire Id No. 201661 Sean P. Mays, Esquire Id No. 307518 Richard J. Nalbandian, III, Esquire Id No. 312653 1310 Industrial Boulevard, Suite 101 Southampton, PA 18966 (215) 942 -2090 ATTORNEYS FOR PLAINTIFF CITIMORTGAGE, INC. COURT OF COMMON PLEAS 1000 TECHNOLOGY DRIVE O'FALLON, MO 63368 CIVIL DIVISION PLAINTIFF CUMBERLAND COUNTY vs. NO. CHARLES L. BOBB COMPLAINT IN LYNNEA D. BOBB MORTGAGE FORECLOSURE NATHANIEL C. BOBB AMY R. BOBB 15 ROUND HILL ROAD CAMP HILL, PA 17011 DEFENDANTS NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 717 - 249 -3166 800 - 990 -9108 R IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.0 § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN T14IRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. t LL EXHIBIT "A" 1t 211 Rai 15 PR 1206 i When Recorded Mail To: Franklin American Mortgage Company 501 Corporate Centre Drive, Suite 400 Franklin, Tennessee 37067 ��tal 0-10-1150 (Space Above This Line For Recording Dotal 80811 MORTGAGE Cam N nb r 441- 7951547- 703 MIN 100052200003860674 I1M ���''� 1 THIS MORTGAGE 'Security Instrument") is given n MAY 11, 2007. The mortgagor is NATHAN1 '&OBB. * 1��, 'MQ� -Mrtli- and CHARL6 ; BOBB and LYNNEABOBB, AS JOINT TENANTS ( "Borrower"). This Security Ai r/5 Instrument is given to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ( "HERS ") (SOLELY AS NOMINEE FOR LENDER, AS HEREINAFTER DEFINED, AND LENDER'S SUCCESSORS AND ASSIGNS), AS BENEFICIARY. MERS IS ORGANIZED AND EXISTING UNDER THE LAWS OF DELAWARE, AND HAS AN ADDRESS AND TELEPHONE NUMBER OF POST OFFICE BOX 2026. FLINT, MICHIGAN 49501 - 2026. -V TELEPHONE (898)679 -MERS. FRANKLIN AMERICAN MORTGAGE COMPANY, a corporation organized and existing `� under the laws of TENNESSEE, and whose address is 501 CORPORATE CENTRE DRIVE. SUITE 400, FRANKLIN, TENNESSEE 37067 ( "Lender"). Borrower owes Lendcr the principal sum of ONE HUNDRED NINETY-NIN THOUSAND FOUR HUNDRED TWENTY -FOUR AND 00 /100ths Dollars (U.S.S199,424.00). This debt is evidenced Borrowces note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the debt. if not paid earlier, due and payable on JUNE 1, 2037. This Security Instrument secures to Lender. (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest. advanced under Paragraph 7 to protect the security of this Security Instrument; and (e) the performance of Borro covenants and agreements under this Security Instrument and the Note. For this (Sttrpose. Borrower does hereby mortgage, grant and convey to MFRS (solely as nominee for Lender and Lceder's successors and assigns) and to the successors and assigns of MFRS the following described property located in CUMBERLAND County, Pennsylvania: i LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF. Tax Parcel Identification Number: 09-20 -1850 -207 which has the address of 1S ROUND HILL ROAD CAMP HILL , lskcdl Ic+al Pennsylvania 17011 ("Property Address "); Iz�r ��I W-093-1 (696) Page l of 6 FHA Pennsylvania Mortgage BK 1992PG 1006 TOGETHER Wfl7{ all the improvements now or hereafter erected on the property, and all casements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agrees that MFRS holds only legal title to the interests granted by Borrower in this Security Instrument: but, if necessary to comply with law or custom, MFRS (as nominee for Lender and Lcndees successors and assigns) has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing and canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Bormwer warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non - uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. - . , 2. Monthly Payment of Taxes, Insurance, and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under Paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of i Housing aril Urban Development ("Secretary "), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items arc called "Escrow Items" and the sums paid to Lender arc called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrowcds escrow account under the Real Estate Settlement Procedures Act of 1974, 12 f U.S.C. § 2601 11 Mg. and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ( "RESPA "), except that the cushion or reserve permitted by RE-SPA for unanticipated disbursements or disbursements before the Borrower's payments arc available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Lender for Escrow items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RGSPA. If the amounts of funds held by Lender at any time arc not sufficient to I pay the Escrow items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RGSPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. if Borrower tenders to Lender the full payment of all such sums, Borrowces account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under Paragraphs I and 2 shall be applied by Lender as follows: EiM to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; ,Seca d. to any tam special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Thi , to interest due under the Note; Fourth to amortization of the principal of the Note; and Li fth to late charges duc under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Larder requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be heW by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. OV2083 -2 (696) Page 2 of 6 FHA Pennsylvania Mortgage BK 1992P61007 in the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower.. Cach insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lendcrjointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in Paragraph 3, and then to prepayment of principal, or (b) to the. restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in Paragraph Z, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. in the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrumcnt (or within.sixty days of a later sale or transfer, of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Burro woes control.. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property.or allow the Property to deteriorate, reasonable wear and tcar excepted. Lender may inspect the Property if the Property is vacant or .abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or : statements to .Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concealing Borrower's occupancy of the Property as a principal residence. if this Security Instrument is on a Icaschold, Borrower shall comply with the provisions of the lease. if Borrower acquires fee title to the property; the leaschold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any i condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and 1 shall be paid to Lender to.the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument, Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, i first to any delinquent amounts applied in the order provided in Paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which arc referred to in Paragraph Z or change the. amount of such payments. , Any excess proceeds over an amount required to pay all outstanding indebtedness under the. Now and Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in Paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment, if failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments.. If Borrower fails to make these payments or the payments required by Paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there a legal proceeding that may significantly affect Lender's rights in the Property .(such as a proceeding in bankruptcy, for condemnation or to enfurcc laws or regulations), then Lender may du and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, ll =ird insurance and other items mentioned in Paragraph 2. Any amounts disbursed by Lender under this Paragraph shall become an additional debt of Borrower and be secured by this Security Instrument, These amounts shall bear interest from the date of disbursement at the Note rate, and at the option of Lender shall be immediately due and payable. Borrower shad promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings. which in the Lender's opinion operate to prevent the enforecrticnt of the tien; or (c) secures from the holderof the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrvnient. If Lender determines that any part of the Property is subjcct.to a lien which may attain priority over this Security instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8, pees. Lender may collect fccs.and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) . Default. Lender may, except as limited by regulations issued by the Secretary in the case of payment defaults. require immediate payment in full of all turns secured by this Security Instrument if. CrV2083 -3 (696) Page 3 of 6 FHA Pennsylvania Mortgage BK I.992PG 1008 I I (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the due date of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including section 341(d) of the Garn-St Germain Depository Institutions Act of 1982, 12 U.S.C. 1701 j -3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if. (i) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property, but his or her credit has not been approved in accordance with the requirements of the Secretary. (e) No Waiver. If circumstances occur that would permit Lender to require immediate payment in full, but Lender does I not require such payments, Lender does not waive its rights with respect to subsequent events. (d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. 'Borrower agrees that if this Security Instrument and the Note arc not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lenders failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrowers failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrowers account current including, to the extent they arc obligations of Borrower under this Security Instrument, forcclosum coats and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement if (i) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Leader Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrowers successor in interest. Lender shall not be required to I commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co- signers. The covenants and agreements of this Security Instrument shall bind and bcnetit the successors and assigns of Lender and Borrower, subject to the provisions of Paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co -signs this Security Instrument but does not execute the Note: (a) is co- signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend. modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrowers consent. r 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. OV20934 (696) Page 4 of 6 FHA Pennsylvania Mortgage 1311 1992PG 1 009 14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that nny provision or.clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 13. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security instrument. 1 16. hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or relelisc of tiny Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation; claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Haiardous'Substance or Environmental Lnw of which Borrower has actual knowledge, If Borrower ]cams, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances. affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this Paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline; kerosene, other flammable. or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive tnatcrials. As used in this Paragraph 16, "Environmental Law" means federal laws and laws of (tic jurisdiction where the Property is Iodated that relate to health, safety or environmental protection. I NON - UNIFORM COVENANTS, Borrower and Lcndcr furthcr,covenant and agree as follows: 17. Assi nment of Rents. Borrower unconditionally assigns and transfers. to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior, to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rcnts_and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of ants canstitutcs an atssolutc assignment and not asp assignment for additional security only. 1 if Lender gives notice of breach to Borrower: (a) all rents .received by Borrower shall be held by Borrower as trustee for. benefit of Lender only, to be applied to the sums secured by the Security instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lcndees written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this Paragraph 17.. Lender shall not be required to enter upon, take control of or maintain the Property Word or after giving notice of breach to Borrower. HoWdycr, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under, Paragraph y, Lender may f6rcclose.this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedics provided in this Paragraph 18, including, but not limited to, attorneys' fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided to the Single Family Mortgage Foreclosure Act of 1994 ( "Act ") (12 U.S.C. 3751 et seq.) by requesting a foreclosure commissioner designated under the Act to comm,encc foreclosure and to sell. the Property as provided to the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragmph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Walvers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects. in proceedings to enforce this :Security instrument. and hereby waives the benefit of any present or future laws providing for stay of execution. extension of time, exemption from attachment, levy and sale, and homestead exemption. I 21. Reinstatement Period. Borrower's time to reinstate provided in Paragraph 10 shall extend to one hour Prior to the E commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument., 22. Purchase Money Mortgage. if any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. GV2083 -5 (69.6) Page 5 of 6 FHA Pennsylvanin Mortgage BK 1992PG 10 10 .z I 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security lnstiumcnt. Check applicable box(es)I I Condominium Rider I Growing Equity Rider Planned Unit Development Rider I Graduated Payment Rider I Other(s) [specify) BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any ridcr(s) exec tcd by Borrower and recorded with it. Witrt , f11 0 7 (Seal Q-� ch'1l NA HAt IEL •aa,e*er ` / sl) HARLES Q (Seal (Scat) t BOBS .9orsow M Q •aarrmvtr I COMMONWEALTH OF ENNSYLVANIA, 1% County ss: On this, the / �y of A -a &1% ¢ 6bax' , fore me, p ,the undersigned officer, personally appeared NATH10 CHARLM SOBB and LYNNEA BOBB known to me (or satisfactorily proven) to be the persons) whose names) istar41ic d to the within i tie and acknowledged that helsheRhey executed the same for the purposes therein contained. Ui2b IN WITNESS WHEREOF, l hereunto set my hand and official seal. � My Commission Expires:, 1q, zomi Title or ommer CERTIFICATE OF RESIDENCE 1, Y Vte L C t2 r'y1� do hereby certify that the correct address of the within -named lender is 501 CORPORATE CENTRE DRIVE, SUITE 400, FRANKLIN, TENNESSEE 37067, witness my hand this I ITH day of MAY, 2007. i C.onunonvreatth Of Penns lvaNa i Not SW gent 6f Lcnder. Moore Cht:r w, Notary Public Hampden Tvrp., 0zfteIand Counly W Omwds*n Elias May 19.2007 Member. PWM*Wia AasodWw Of NArks GV2083 -6 (696) Page 6 of 6 FHA Pennsylvania Mortgage BX I 992PG 10 11 EXHIBIT A ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows to wit: BEGINNING at a point on the southern line of Round HIII Road which point Is at the dividing line between Lots Nos. 3 and 4 on Plan of Lots hereinafter mentioned; thence South 9 degrees 27 minutes 30 seconds East and along the dividing line between Lot No. 3 and 4 on Plan of lots hereinafter mentioned, a distance of 102.17 feet to a point on the line of Hollywood Development; thence South 88 degrees 04 minutes West and along line of Hollywood Development, a distance of 85.03 feet to a point at the dividing line between Lots Nos. 2 and 3 on Plan of Lots hereinafter mentioned; thence North 01 degree 56 minutes West and along the dividing line between lots Nos. 2 and 3 on Plan of Lots hereinafter mentioned, a distance of 100 feet to a point on the southern line of Round Hill Road; thence North 88 degrees 04 minutes East and along the southern line of Round Hill Road, a distance of 52.10 feet to a point: thence continuing along the southern line of Round Hill Road and on a curve to the left whose radius is 150 feet a distance of 19.7 feet to a point, the point and place of beginning. BEING Lot No. 3 on Plan of Lots known as Part of Country Club Park which Is recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 35. HAVING thereon erected a two story brick and frame dwelling with attached garage known as and numbered 15 Round Hill Road, Camp Hill, PA 17011 PREMISES BEING: 15 Round Hill Road; Camp Hill, PA 17011 Parcel No. 09 -20 -1850 -207 ije recorded t urltbc;rla�d t'ounty PA �-� Recorder of Deeds SK1992PG1012 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. (Check applicable box(es)} I Condominium Rider I Growing Equity Rider I Planned Unit Development Rider I Graduated Payment Rider Other(s) [specify] BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any rider(s) exec ted by Borrower and recorded with it. Witn �� f 0 7 (Seal) to �^ O tt NATHANIEL BOBB -twno a Lti al) 60 ARLES * I (Seal (Seal) BOBS - aomnt, o - an+,oaer I COMMONWEALTH NNSYLVANIA, OF E Il County ss: On this, the /l day of CA Ar b , efore me, p the undersigned officer, personally appeared NATH�IEL CHARLES�80BB and LYNNEA BOBB known to me (or satisfactorily proven) to be the person(s) whose name(s) is/are ybcer ed to the within i trum and acknowledged that he/she/thcy executed the same for the purposes therein contained. 4 /� U IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: tqr z'01 (J eiets:; y — I Tide of otrccr (hand ERTIFICATE OF RESIDENCE T, YVtC C Ln3_MC do hereby certify that the correct address of the ithin -named lender is 501 CORPORATE CENTRE DRIVE, SUITE 400, FRANKLIN, TENNESSEE 37067, witness my this 11TH day of MAY, 2007. 11 10 Cominmwealth or Penns vanta NoWbiSeai gent 6f Lcnder. NwbCht rw NotaryPuble rim pft TWp., tAamb ft d County My Cor =bs1 n Ev[rw May 19, 2007 Member.Penr60er6Aswchdi m0r - k 1 g OV2083 -6 (696) Page 6 of 6 FHA Pennsylvania Mortgage BKI992PG1011 i EXMMIT A ALL THAT CERTAIN piece or parcel of land situate in East Pennsb= Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows to wit: BEGINNING at a point on the southern line of Round Hill Road which point is at the dividing line between Lots Nos. 3 and 4 on Plan of Lots hereinafter mentioned; thence South 9 degrees 27 minutes 30 seconds East and along the dividing line between Lot No. 3 and 4 on Plan of Lots hereinafter mentioned, a distance of 102.17 feet to a point on the line of Hollywood Development; thence South 88 degrees 04 minutes West and along line of Hollywood Development, a distance of 85.03 feet to a point at the dividing line between Lots Nos. 2 and 3 on Plan of tots hereinafter mentioned; thence North 01 degree 56 minutes West and along the dividing line between Lots Nos. 2 and 3 on Plan of lots hereinafter mentioned, a distance of 100 feet to a point on the southern line of Round Hill Road; thence North 88 degrees 04 minutes East and along the southem line of Round Hill Road, a distance of 52.10 feet to a point; thence continuing along the southern line of Round Hill Road and on a curve to the left whose radius is 150 feet a distance of 19.7 feet to a point, the point and place of beginning. BEING Lot No. 3 on Plan of Lots known as Part of Codntry Club Park which Is recorded In the Office of the Recorder of Deeds in and for Cumberland County In Plan Book 12, Page 35. HAVING thereon erected a two story brick and frame dwelling with attached garage known as and numbered 15 Round Hill Road, Camp Hill, PA 17011 PREMISES BEING: 15 Round Hill Road, Camp Hill, PA 17011 Parcel No. 09-20- 1850 -207 tiiti. recorded ('uniberland (7unty PA Recorder of Decds B1t1992PG1012 EXHIBIT "B" I , - Return To: CT LIEN SOLUTIONS 0 20LD III; PO BOX 29071 I GLENDALE, CA 91209.9071 Phone #: 800 - 331 -3282 - I , Prepared By: f CITIMORTGAGE, INC ' GEORGIA BRUMIT 1000 Technology Drive, MS 321 O'Fallon, MO 63368-2240 f i Parcel No: 09- 20- 1850 -207 milli 111111111111111 1 ASSIGNMENT OF MORTGAGE f MERS SIS # 888 -679 -6377 MIN: 100052200003860674 KNOW ALL MEN BY THESE PRESENTS that Curl'eritBeneficiary Mortgage Electronic Registration Systems, Inc. as nominee for Franklin American Mortgage' Company, whose address is 1901 E Voorhees i St. Danville, IL 61834, P.O. Box 2026, Flint, MI, 48501 -2026, its successors and assigns, hereinafter i . Assignor the holder of the Mortgage hereinafter mentioned, for and in consideration of the sum of ONE DOLLAR ($1.00) lawful money unto it in hand paid by CitiMortgage, Inc., 1000 Technology Drive, O'Fallon, MO, 63368, Assignee at the time of execution hereof, sell, assign, transfer and set over unto the said Assignee, the receipt whereof is hereby acknowledged, does hereby grant, bargain, its successors j and assigns, ALL THAT CERTAIN Indenture of Mortgage given and executed by Nathaniel C. Bobb, Amy R. Bobb, Charles L. Bobb, and Lynnea D. Bobb to Original Beneficiary: Mortgage Electronic Registration Systems, Inc. as nominee for Franklin American Mortgage Company, bearing the date 0511112007, in the amount of $199,424.00, said Mortgage being recorded on Originally Recorded On: 05/15/2007 in the County of Cumberland County, Commonwealth of Pennsylvania, in Book: 1992 Page: 1006. Being Known as Premises: 15 Round Hill Road, Camp Hill, PA, 17011 Township: East Pennsboro Legal Description: See exhibit A. Together with all Rights, Remedies and incidents thereunto belonging. And all its Right, Title, Interest, I Property, Claim and Demand, in and to the same; TO HAVE, HOLD, RECEIVE AND TAKE, all and singular the hereditaments and premises hereby granted and assigned, or mentioned and intende(�so to.be, with the appurtenances unto Assignee, its successors and assigns, to and for its only proper VA enefit and behoof forever; subject, nevertheless, to the equity of redemption of said Mortgagor in ttie said7ridenture of Mortgage named, and his /her /their heirs and assigns therein. IN WITNESS WHEREOF, the said Asslanor has caused its Corporate Seal to be herein affixed and these presents to be duly executed by its proper officers { 1 This 06/27/2012 Page # 1 33791996 24449 PA57D Cumberland County internal __ _ ___ � Mf✓MNpIYNl NY • l i I 1 • � Mortgage Electronic Registration Systems, Inc. as nominee for Franklin Ame rican Mor Compan P Y i A A Z741 J'9 Georgi A. B it . ..r. "•��ROf+tlC��h'��9 Vice President. G Sealed and Delivered in the Presence of us; : a w. s � A �' 9= :02 Attes AnnL �C- � s� C� •� ' 2 Geraldine A. Belinski ' - s;` ,qRE. , •�y�+� (_ STATE OF MISSOURI, ST. CHARLES COUNTY On June 27, 2012 before me, the undersigned, a notary public in and for said state, personally appeared Georgia A. Brumit, Vice President of Mortgage Electronic Registration Systems, Inc. as nominee for Franklin American Mortgage Company personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged to me that he/she executed the same in his/her capacity, and that by hislher signature on . the instrument, the Individual, or the person upon behalf of which the individual acted, executed the , i instrument. 1 SYBIL SHORT Nosy Publc - Notary Seal State of Mmouri COMMISSIOned for SL Louts County j C m 1 is 'Noe y Public Sybil Short Commission Expires: 03/19/2016 The precise address within named Assignee is: f ; 1000 Technology Drive, O'Fallon, MO, 63368 j By Ga-- aft L r i i Page # 2 33791996 24449 PA570 Cumberland County Intem I) 1 t EXHIBIT A 1 i r i ALL THAT anm piety or parcel of land situate In East PennsWro Towrahlp, Cumberland County, CW m wwmIth of Pennsylvania, more particularly bounded and descrted as follows to Wt: i BEGINNING at a point an the southern line of Rlwnd MI Road which print is a 1 the Ming On bdween Lots Nos. 3 and 4 on Plan o f Lots hereinafter i mentioned; thence South 9 degrees 27 minutes 30 seconds East along the dividlng fine between toot No. 3 and 4 or* Plan of Lots hereinafter mentioned, a 1 061znce of 102,17 feet to a point on the line of Hollywood Development; thence South 88 degrees 04 minutes West.and alcx*q, ilne of Hollywood Development, a distance of 85.03 feet to a paint at 64 dividing one between lots Nos. 2 and 3 i On Plan of lots thereinafter mentioned; tfterroe Nora► 01 degree 58 minutes West and along the dMding line between lots Nos. 2 mid 3 on M of Loots herebuter mentioned, a dissance of 100 feet to a point on the sout line of Round Hill Road; thence North 88 degrees 04 mhhutes.East arld along the southem line of Rowd 'Hill Road, a dtancs of 52.10 feat ta.a. Q0104 therwe tOMnuing along the southern line of Round HID Rid and on a curve to the left whose radius Is 150 feet a distance of 19.7 #eel to a pant, the point and place of beginning. BEING Lot No. 3 on Plan of Lots iamn as Part of Country Club Park which Is recorded In the Office of the Recorder of Deeds In and for Cumberland County In Plan Book 12, Page 35. I HAVING thereon erected a two shay brick aril frame dwelling with attached ! garage known as and numbered 15 Round Hill hood, Camp 14111, PA 17011 PREMISES BEING: 15 Round Hill Road, Camp KII, PA 17011 I t l t I I .... .....w—. �-w .sty • �.� . � .- .......�•, . w.. �.. wse .'....+.w.»w.......a.+..,... . f i ROBERT P. ZIEGLER RECORDER OF DEEDS ' CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 { 717 - 240 -6370 Instrument Number - 201219463 Recorded On 6/29/2012 At 10:53:22 AM Total Pages - 4 l • Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 111655 User ID - MSW € • Mortgagor - BOBB, CHARLES L • Mortgagee - CITIMORTGAGE INC ' • Customer - CT LEIN SOLUTIONS * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $12.00 I RECORDER of DEEDS This page is now part r PARCEL CERTIFICATION $10.00 FEES of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 j TOTAL PAID $51.00 I Certify this to be recorded f in Cumberland County PA l ou RECORDER O D EDS I + - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. :. 002OLD 1f�llll�il��llf1111!l1111 f f w+....�ww-H w-.:. nww i. H�taw•. M# l+ �Piew�.n.w,ww.eww.w«+.... -.�.. �...�..... �.._...t..,.... n, .. ...,- ... —er ' EXHIBIT "C" MAY 11, 2007 [Date] 15 ROUND HILL ROAD, CAti1P HILL, PENNSYLVANIA 17011 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person`s successors and assigns. "Lender" means FRANKLIN AMERICAN MORTGAGE COMPANY and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of ONE HUNDRED NINETY -NINE THOUSAND FOUR HUNDRED TWENTY -FOUR AND 00 /100ths Dollars (U.S.S199,424.00), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of SIX AND THREE - EIGHTHS percent (6.375 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANLIER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the 1ST day of each month beginning on JULY 1, 2007. Any principal and interest remaining on the 1ST day of JUNE, 2037, will be due on that date, which is called the maturity date. (B) Place Payment shalt be made at 501 CORPORATE CENTRE DRIVE, SUITE 400, FRANKLIN, TENNESSEE 37067 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $1,244.15. This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box.] i Graduated Payment Allonge I Other [Specify] I Growing Equity 'Allonge 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR percent ( 4.00 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full. of the principal balance remaining due and all 'accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD' regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(13) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this. Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. (Seal) NATHANI L BOBB - Bolwww /� D (Seal) IL BOBB 1/ -Borrower t 1 (Seal) LkDA EV, BOBB 8otrower 1 PAY TO THE ORDER OF WITHOUT RECOURSE FRANKLIN AMERICAN MORTGAGE COMPANY BY: Dear NATHANIEL BOBB, You are hereby notified that the servicing of your mortgage loan, that is the right to collect payments from you, is being assigned from FRANKLIN AMERICAN MORTGAGE COMPANY to CITIMORTGAGE, INC. effective with your 07/01/2007 payment. The assignment, sale, or transfer of the servicing of the mortgage loan does not affect any term or condition of the mortgage instruments, other than terms directly related to the servicing of your loan. Except in limited circumstances, the law requires that your present servicer send you this notice at least 15 days before the effective date of transfer, or at closing. Your new servicer must also send you this notice no later than 15 days after this effective date or at closing. Your present servicer is FRANKLIN AMERICAN MORTGAGE COMPANY. If you have any questions relating to the transfer of servicing please contact them at (866) 510 -8930 Your new servicer will be CITIMORTGAGE, INC. 1000 TECHNOLOGY DRIVE OVALLON, MO 63368 -2240 If you have any questions relating to the transfer of servicing to your new servicer, call their customer service department at 800 - 283 -7918 between the hours of 8:00 a.m. ET and 12:00 midnight ET, Monday through Friday. Saturday, 9:00 am ET until 6:00 pm ET. This is a toll -free number. Effective with your 07/01/2007 payment, FRANKLIN AMERICAN MORTGAGE COMPANY will not accept payments from you. Such payments will be accepted and processed by CITIMORTGAGE, INC.. Payment instructions will be sent via separate correspondence. You will soon receive a coupon book or monthly statement containing payment coupons. In the unlikely event that you do not receive a payment coupon, you should write your new loan number, referenced above, on your check i and mail to: I CITIMORTGAGE, INC. PO BOX 8003 S. HACKENSACK, NJ 07606 - If your mortgage payment with FRANKLIN AMERICAN MORTGAGE COMPANY includes premiums for mortgage life /disability or other type of optional insurance plans, the transfer of servicing rights will affect the continuance of these premium collections. To retain your current insurance premium collections and/or coverage, you must contact FRANKLIN AMERICAN MORTGAGE COMPANY at (866) 510 -8830. Failure to do so will result in the loss or lapse of your current optional insurance coverage. If you use a bill payment service, please notify them of the changes. Automatic payments through checking or savings accounts will be discontinued upon the transfer of your loan. You should also be aware of the following information. which is set out in more detail in Section 6 of the Real Estate Settlement Procedures Act (RESPA) (12 U.S.C. 2605): During the 60 -day period following the effective date of the transfer of the loan servicing, a loan payment received by your old servicer before its due date may not be treated by the new loan servicer as late, and a late fee may not be imposed on you. Section 6 of RESPA (12 U.S. C. 2605) gives you provisions for certain consumer rights. If you send a 'qualified written request" to your loan servicer concerning the servicing of your loan, your servicer must provide you with a written acknowledgement within 20 business days after receipt of your request. A "qualified written request" is written correspondence, other than notice on a oavment coupon or other oavment medium sunolied by the sPrvicer which inrJiides vnnr name and nrrnnnf nrnmhar EXHIBIT "D" CitiMortgage, Inc PRESORT PO Box 9090 First -Class Mail Temecula, CA 92589 -9090 U.S. Postage and Fees Paid W SO 7196 9006 9295 8745 7859 Send Payments to: CitiMortgage, Inc PO Box 689196 Des Moines, IA 50368 -9196 20120323 -168 �nrill�Intilllr��Ilr' IIII�I�illinn�Irr�rl�ulilllll�I� NATHANIEL BOBB 15 ROUND HILL RD Send Correspondence to: CAMP HILL, PA 17011 -2636 CitiMortgage, Inc 6400 Las Colinas Blvd. Irving, TX 75063 6N CITIPAACT6 CitiMortgage citi www.citimortgage.com 03/23/2012 NATHANIEL BOBB 15 ROUND HILL RD CAMP HILL, PA 17011 -2636 RE: Property: 15 ROUND HILL ROAD CAMP HILL, PA 17011 Loan No.:► Mortgages: CitiMortgage, Inc. NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of PA Act No. 6 of 1974. (READ ALL -PAGES OF THIS NOTICE CAREFULLY) Dear CitiMortgage Custorner(s): If you have filed bankruptcy, CitiMortgage is providing this notice to you for compliance and informational purposes as lender or servicing agent for the lender and is not attempting to collect a debt from you (deficiency or otherwise) or in any way violate the provisions of the United States Bankruptcy Code. The MORTGAGE held by CitiMortgage, Inc. (hereinafter we, us or ours) on your property located at the above noted property address, IS IN SERIOUS DEFAULT, because you have not made the monthly payments as noted below under (a). Late and other charges have also accrued to this date in the amount noted below under (b and c). Unapplied Funds received (if applicable) reflect under (d). The total amount now required to cure this default, as of the date of this letter, is noted below under (e). (a) 01/01/12 thru 03/01/12 3 @ $1,570.09 /month 3 @ $49.76 /late charge /month $4,859.55 (b) Previous late charge(s) $86.02 (c) Delinquency Expense(s) $94.50 (d) Unapplied Funds $ (e)TOTAL AMOUNT (a) +(b)+(c)±(d) REQUIRED AS OF THIS DATE: $5,040.07 You may cure this default by April 27, 2012 (or the next business day thereafter if April 27, 2012 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (d) above. Any additional payments and late charges that fall due during this period must; also be paid to bring your loan current. Please submit payment to the following address: CitiMortgage, Inc. Loan Payments P.O. Box 689196 Des Moines, IA 50368 -9196 020t1 CitiMortgage, Inc. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. CitiMortgage, Inc is an equal housing lender. Citi, Arc Design, and Citi and Arc Design are registered service marks of Citigroup Inc. "Calls are randomly monitored and recorded for quality assurance. CitiMortgage is a debt collector and any " " "" Information obtained will be used for that purpose. CITIPAACT6 7196 9006 9295 8745 7659 Page 1 of 3 ;e ;4 If you do not cure the default by April 27, 2012, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original. mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by April 27, 2012, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default by April 27, 2012, you will not be required to pay attorney's fees. Also, we may sue you personally for the unpaid principal balance, and all other suns due under the mortgage. If you have not cured the default by April 27, 2012, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff s sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number, (8Q0),723- 7906 *. You should realize that a Sheriffs sale will end your : owrier''ship of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have the right to reinstate after acceleration and the right to bring a court action or assert in any foreclosure proceeding, the non - existence of a default or any other defense you have to acceleration and the sale of the property. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR TO, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. Under IRS regulation, we must report any foreclosure to the IRS on form 1099 -A. The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information. If your delinquency is a result of a loss of employrneiit inco* or a reduction in employment income you may be eligible for homeownership counseling from one of the Department of Housing and Urban Development ( "HUD ") approved homeownership counseling agencies. Please call us at (800) 723 -7906* for information regarding the HUD - approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our Loan Counselors. CITIPAACT6 7196 9006 9295 8745 7859 Page 2 of 3 w If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, Collection Department CitiMortgage, Inc. *CALLS ARE RANDOMLY MONITORED AND RECORDED TO ENSURE QUALITY SERVICE. This is an attempt to collect a debt, and any information obtained will be used for that purpose. In the event you are subject to an Automatic Stay issu6d by a`?IVuited States Bankruptcy Court or the referenced debt has been discharged in Bankruptcy, this communication is not intended to be an attempt to collect a debt. If an attorney represents you, please refer this letter to such attorney and provide us with such attorney's name, address and telephone number. EMIt CITIPAACT6 7196 9006 9295 8745 7859 Page 3 of 3 } CitiMortgage, Inc PRESORT PO Box 9090 First -Class Mail Temecula, CA 92589 -9090 U.S. Postage and Fees Paid W SO 7196 9006 9296 1458 1335 Send Payments to: CitiMaigage, Inc PO Box 689196 Des Moines, IA 50368 -9196 20120810 -166 IIrnllln irlll�lillillll „ linilllllirii , lllilrin , ll , ill NATHANIEL BOBB 245 BIRDIE LN Send Correspondence to: ETTERS, PA 17319 -9712 CitiMortgage, Inc 6400 Las Colinas Blvd. Irving, TX 75063 CITIPAACT6 1 CitiMortgage Citi www.citimortgage.com 08/10/2012 NATHANIEL BOBB 245 BIRDIE LN ETTERS, PA 17319 -9712 RE: Property: 15 ROUND HILL ROAD CAMP HILL, PA 17011 Loan No.: Mortgagee: CitiMortgage, Inc. NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 443 of PA Act No. 6 of 1974. (READ ALL PAGES OF THIS NOTICE CAREFULLY Dear CitiMortgage Customer(s): If you have filed bankruptcy, CitiMortgage is providing this notice to you for compliance and informational purposes as lender or servicing agent for the lender and is not attempting to collect a debt from you (deficiency or otherwise) or in any way violate the provisions of the United States Bankruptcy Code. The MORTGAGE held by CitiMortgage, Inc. (hereinafter we, us or ours) on your property located at the above noted property address, IS IN SERIOUS DEFAULT, because you have not made the monthly payments as noted below under (a). Late and other charges have also accrued to this date in the amount noted below under (b and c). Unapplied Funds received (if applicable) reflect under (d). The total amount now required to cure this default, as of the date of this letter, is noted below under (e). (a) 01/01/12 thru 08/01/12 8 @ $1,570.09 /month 7 @ $49.76/late charge/month $12,909.04 (b) Previous late charge(s) $86.02 (c) Delinquency Expense(s) $148.50 (d) Unapplied Funds 300.00 (e)TOTAL AMOUNT (a)+(b)+(c)±(d) REQUIRED AS OF THIS DATE: $12,843.56 You may cure this default by September 14, 2012 (or the next business day thereafter if September 14, 2012 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (d) above. Any additional payments and late charges that fall due during this period must also be paid to bring your loan current Please submit payment to the following address: CitiMortgage, Inc. Loan Payments P.O. Box 689196 Des Moines, IA 50368 -9196 02012 CitiMortgage, Inc. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. CitiMortgage, Inc is an equal housing lender. Citi. Arc Design, and Citi and Arc a Design are registered service marks of Citigroup Inc. "Calls are randomly monitored and recorded for- quality assurance. CitiMortgage is a debt collector and any LE..ER information obtained will be used for that purpose. CITIPAACT6 7196 9006 9296 1458 1335 Page 1 of 3 If you do not cure the default by September 14, 2012, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by September 14, 2012, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorneys fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default by September 14, 2012, you will not be required to pay attorney's fees. Also, we may sue you personally for the unpaid principal balance, and all other sums due under the mortgage. If you have not cured the default by September 14, 2012, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait You may find out at any time exactly what the required payment will be by calling us at the following number: (800) 723 - 7906 *. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict YOU. You have the right to reinstate after acceleration and the right to bring a court action or assert in any foreclosure proceeding, the non - existence of a default or any other defense you have to acceleration and the sale of the property. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR TO, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. Under IRS regulation, we must report any foreclosure to the IRS on form 1099 -A The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information. If your delinquency is a result of a loss of employment income or a reduction in employment income you may be eligible for homeownership counseling from one of the Department of Housing and Urban Development ( "HUD ") approved homeownership counseling agencies. Please call us at (800) 723 -7906* for information regarding the HUD - approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our Loan Counselors. CITIPAACT6 7196 9006 9296 1458 1335 Page 2 of 3 If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, Collection Department CitiMortgage, Inc. *CALLS ARE RANDOMLY MONITORED AND RECORDED TO ENSURE QUALITY SERVICE. This is an attempt to collect a debt, and any information obtained will be used for that purpose. In the event you are subject to an Automatic Stay issued by a United States Bankruptcy Court or the referenced debt has been discharged in Bankruptcy, this communication is not intended to be an attempt to collect a debt. If an attorney represents you, please refer this letter to such attorney and provide us with such attorney's name, address and telephone number. CITIPAACT6 7196 9006 9296 14'Sd_ E335 Page 3of3 CitiMortgage, Inc PRESORT PO Box 9090 First -Class Mail Temecula, CA 92589 -9090 U.S. Postage and Fees Paid W SO 7196 9006 9295 8745 7842 Send Payments to: CitiMortgage, Inc PO Box 689196 Des Moines, IA 50368 -9196 20120323 -168 II�I�I��' �I �' I ' I lll l l�' I 'I��'�I CHARLES BOBB 15 ROUND HILL RD Send Correspondence to: CAMP HILL, PA 17011 -2636 CiUMortgage, Inc 6400 Las Colinas Blvd. Irving, TX 75063 CITIPAACT6 �. CitiMortg Citi www.citimortga9e.com 03/23/2012 CHARLES BOBB 15 ROUND HILL RD CAMP HILL, PA 17011 -2636 RE: Property: 15 ROUND HILL ROAD CAMP HILL, PA 17011 Loan No.. 40000ow Mortgagee: CitiMortgage, Inc. NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of PA Act No. 6 of 1974. (READ ALL PAGES OF THIS NOTICE CAREFULLY) Dear CitiMortgage Customer(s): If you have filed banlauptcy, CitiMortgage is providing this notice to you for compliance and informational purposes as lender or servicing agent for the lender and is not attempting to collect a debt from you (deficiency or otherwise) or in any way violate the provisions of the United States Bankruptcy Code. The MORTGAGE held by CitiMortgage, Inc. (hereinafter we, us or ours) on your property located at the above noted property address, IS IN SERIOUS DEFAULT, because you have not made the monthly payments as noted below under (a). Late and other charges have also accrued to this date in the amount noted below under (b and c). Unapplied Funds received (if applicable) reflect under (d). The total amount now required to cure this default, as of the date of this letter, is noted below under (e). (a) 01/01/12 thru 03/01/12 3 @ $1,570.09 /month 3 @ $49.76 /late charge/month $4,859.55 (b) Previous late charge(s) $86.02 (c) Delinquency Expense(s) $94.50 (d) Unapplied Funds $ (e)TOTAL AMOUNT (a)+(b) +(c)±(d) REQUIRED AS OF THIS DATE: $5,040.07 You may cure this default by April 27, 2012 (or the next business day thereafter if April 27, 2012 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (d) above. Any additional payments and late charges that fall due during this period must also be paid to bring your loan current. Please submit payment to the following address: CitiMortgage, Inc. Loan Payments P.O. Box 689196 Des Moines, IA 50368 -9196 W011 CitiMortgage, Inc. CitiMortgage. Inc. does business as Citicorp Mortgage in NM. CitiMortgage, Inc is an equal housing lender. Citi, Arc Design, and Citi and Arc Design are registered service marks of Citigroup Inc. 'Calls are randomly monitored and recorded for quality assurance. CitiMortgage is a debt collector and any " " "" information obtained will be used for that purpose. CITIPAACT6 7196 9006 9295 8745 7842 Page 1 of 3 �1 If you do not cure the default by April 27, 2012, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by April 27, 2012, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default by April 27, 2012, you will not be required to pay attorney's fees. Also, we may sue you personally for the unpaid principal.balance, and all other sums due under the mortgage. If you have not cured the default by April 27, 2012, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of the Sheriffs sale will be sent 'to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (800) 723 - 7906 *. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have the right to reinstate after acceleration and the right to bring a court action or assert in any foreclosure proceeding, the non - existence of a default or any other defense you have to acceleration and the sale of the property. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR TO, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. Under IRS regulation, we must report any foreclosure to the IRS on form 1099 -A. The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information. If your delinquency is a result of a loss of employment income or a reduction in employment income you may be eligible for homeownership counseling from one of the Department of Housing and Urban Development ( "HUD ") approved homeownership counseling agencies. Please call us at (800) 723 -7906* for information regarding the HUD - approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our Loan Counselors. CITIPAACT6 7196 9006 9295 8745 7842 Page 2 of 3 If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, Collection Department CitiMortgage, Inc. *CALLS ARE RANDOMLY MONITORED AND RECORDED TO ENSURE QUALITY SERVICE. . ;i This is an attempt to collect a debt, and any information obtained will be used for that purpose. In the event you are subject to an Automatic Stay issued by a United States Bankruptcy Court or the referenced debt has been discharged in Bankruptcy, this communication is not intended to be an attempt to collect a debt. If an attorney represents you, please refer this letter to such.attorney and provide us with such attorney's name, address and telephone number. CITIPAACT6 7196 9006 9295 8745 7842 Page 3 of 3 CitiMortgage, Inc PRESORT PO Box 9090 First -Class Mail Temecula, CA 92589 -9090 U.S. Postage and Fees Paid WSO 7196 9006 9296 1458 1342 Send Payments to: CitiMortgage, Inc PO Box 689196 Des Moines, IA 50368.9196 20120810 -168 II�I1 ���II�II�� � CHARLES BOBB 245 BIRDIE LN Send Correspondence to: ETTERS, PA 17319 -9712 CitiMor1gage, Inc 6400 Las Colinas Blvd. Irving, TX 75063 CITIPAACT6 �1 a CitiMortg g e C Iti www.citimortgage.corn 08/10/2012 CHARLES BOBB 245 BIRDIE LN ETTERS, PA 17319 -9712 RE: Property: 15 ROUND HILL ROAD CAMP HILL, PA 17011 Loan No.: Mortgagee: CitiMortgage, Inc. NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of PA Act No. 6 of 1974. (READ ALL VAGES OF THIS NOTICE CAREFULLY) Dear CitiMortgage Customer(s): If you have filed bankruptcy, CitiMortgage is providing this notice to you for compliance and informational purposes as lender or servicing agent for the lender and is not attempting to collect a debt from you (deficiency or otherwise) or in any way violate the provisions of the United States Bankruptcy Code. The MORTGAGE held by CitiMortgage, Inc. (hereinafter we, us or ours) on your property located at the above noted property address, IS IN SERIOUS DEFAULT, because you have not made the monthly payments as noted below under (a). Late and other charges have also accrued to this date in the amount noted below under (b and c). Unapplied Funds received (if applicable) reflect under (d). The total amount now required to cure this default, as of the date of this letter, is noted below under (e). (a) 01/01/12 thru 08/01/12 8 @ $1,570.09 /month 7 @ $49.76/late charge/month $12,909.04 (b) Previous late charge(s) $86.02 (c) Delinquency Expense(s) $148.50 (d) Unapplied Funds 300.00 (e)TOTAL AMOUNT (a) +(b)+(c)±(d) REQUIRED AS OF THIS DATE: $12,843.56 You may cure this default by September 14, 2012 (or the next business day thereafter if September 14, 2012 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (d) above. Any additional payments and late charges that fall due during this period must also be paid to bring your loan current. Please submit payment to the following address: CitiMortgage, Inc. Loan Payments P.O. Box 689196 Des Moines, IA 50368 -9196 Ef, /� @2012 CitiMortgage, Inc. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. CitiMortgage, Inc is an equal housing lender. Citi, Arc Design, and Citi and Arc 7 — f Design are registered service marks of Citigroup Inc. *Calls are randomly monitored and recorded for quality assurance. CitiMortgage is a debt collector and any " "'E" information obtained will be used for that purpose. CITIPAACT6 7196 9006 9296 1458 1342 Page 1 of 3 w If you do not cure the default by September 14, 2012, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by September 14, 2012, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default by September 14, 2012, you will not be required to pay attorney's fees. Also, we may sue you personally for the unpaid principal balance, and all other sums due under the mortgage. If you have not cured the default by September 14, 2012, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff s sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (800) 723 - 7906 *. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict YOU. You have the right to reinstate after acceleration and the right to bring a court action or assert in any foreclosure proceeding, the non - existence of a default or any other defense you have to acceleration and the sale of the property. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR TO, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. Under IRS regulation, we must report any foreclosure to the IRS on form 1099 -A. The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information. If your delinquency is a result of a loss of employment income or a reduction in employment income you may be eligible for homeownership counseling from one of the Department of Housing and Urban Development ( "HUD ") approved homeownership counseling agencies. Please call us at (800) 723 -7906* for information regarding the HUD - approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our Loan Counselors. CITIPAACT6 7196 9006 9296 1458 1342 Page 2of3 If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, Collection Department CitiMortgage, Inc. *CALLS ARE RANDOMLY MONITORED AND RECORDED TO ENSURE QUALITY SERVICE. This is an attempt to collect a debt, and any information obtained will be used for that purpose. In the event you are subject to an Automatic Stay issued by a United States Bankruptcy Court or the referenced debt has been discharged in Bankruptcy, this communication is not intended to be an attempt to collect a debt. If an attorney represents you, please refer this letter to such attorney and provide as with such attorney's name, address and telephone number. CITIPAACT6 7196 9006 9296 1458 1342 Page 3 of 3 CiliMortgage, Inc PRESORT PO Box 9090 First -Class Mail Temecula, CA 92589 -9090 U.S. Postage and Fees Paid W SO 7196 9006 9295 8745 7835 Send Payments to: CiliMortgage, Inc PO Box 689196 Des Moines, IA 50368 -9196 20120323 -168 Iltl II1114IInInI�IIIIIIIrIIIIIrII��IIiIrInll�illlnlllnr LYNNEA BOBB 15 ROUND. HILL RD. Send Correspondence to: CAMP HILL, PA 17011 -2636 CniMortgage, Inc 6400 Las Colinas Blvd - Irving, TX 75063 0 J CITIPAACT6 4 �. • CitiMortgage ati www.citimortgage.com 03/23/2012 LYNNEA BOBB 15 ROUND HILL RD CAMP HILL, PA 17011 -2636 RE: Property: 15 ROUND HILL ROAD CAMP HILL, PA 17011 Loan No.. Mortgagee: CitiMortgage, Inc. NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of PA Act No. 6 of 1974. (READ ALL PAGES OF THIS NOTICE CAREFULLY) Dear CitiMortgage Custorner(s): If you have filed barlduaptcy, CitiMortgage is providing this notice to you for compliance and informational purposes as lender or servicing agent for the lender and is not attempting to collect a debt from you (deficiency or otherwise) or in any way violate the provisions of the United States Bankruptcy Code. The MORTGAGE held by CitiMortgage, Inc. (hereinafter we, us or ours) on your property located at the above noted property address, IS IN SERIOUS DEFAULT, because you have not made the monthly payments as noted below under (a). Late and other charges have also accrued to this date in the amount noted below under (b and c). Unapplied Funds received (if applicable) reflect under (d). The total amount now required to cure this default, as of the date of this letter, is noted below under (e). (a) 01/01/12 thru 03/01/12 3 @ $1,570.09 /month 3 @ $49.76 /late charge/month $4,859.55 (b) Previous late charge(s) $86.02 (c) Delinquency Expense(s) $94.50 (d) Unapplied Funds $0. (e)TOTAL AMOUNT (a) +(b)+(c)t(d) REQUIRED AS OF THIS DATE: $5,040.07 You may cure this default by April 27, 2012 (or the next business day thereafter if April 27, 2012 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (d) above. Any additional payments and late charges that fall due during this period must also be paid to bring your loan current. Please submit payment to the following address: CitiMortgage, Inc. Loan Payments P.O. Box 689196 Des Moines, IA 50368 -9196 2011 CitiMortgage, Inc. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. CitiMortgage, Inc is an equal housing lender. Citi. Arc Design, and Citi and Arc u Design are registered service marks of Citigroup Inc. 'Calls are randomly monitored and recorded for quality assurance. CitiMortgage is a debt collector and any LE.EP information obtained will be used for that purpose. CITIPAACT6 7196 9006 9295 8745 7835 Page 1 of 3 r • If you do not cure the default by April 27, 2012, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by April 27, 2012, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default by April 27, 2012, you will not be required to pay attorney's fees. Also, we may sue you personally for the unpaid principal balance, and all other sums due under the mortgage. If you have not cured the default by April 27, 2012, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unp4id'monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs con' &ted with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (800) 723 - 7906'x. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have the right to reinstate after acceleration and the right to bring a court action or assert in any foreclosure proceeding, the non - existence of a default or any other defense you have to acceleration and the sale of the property. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR TO, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE; UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. Under IRS regulation, we must report any foreclosure to the IRS on form 1099 -A. The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information. If your delinquency is a result of a loss of employment income or a reduction in employment income you may be eligible for homeownership counseling from one of the Department of Housing and Urban Development ( "HUD ") approved homeownership counseling agencies. Please call us at (800) 723 -7906* for information regarding the HUD - approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our Loan Counselors. CITIPAACT6 7196 9006 9295 8745 7835 Page 2 of 3 a If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your, default more than three (3) times in any calendar year. Sincerely, Collection Department CitiMortgage, Inc. *CALLS ARE RANDOMLY MONITORED AND RECORDED TO ENSURE QUALITY SERVICE. This is an attempt to collect a debt, and any information obtained will be used for that purpose. In the event you are subject to an Automatic Stay issued by a United States Bankruptcy Court or the referenced debt has been discharged in Bankruptcy, this communication is not intended to be an attempt to collect a debt. If an attorney represents you, please refer this letter to such attorney and provide us with such attorney's name, address and telephone number. 3'. CITIPAACT6 7196 9006 9295 8745 7835 Page 3 of 3 • r , r CitiMortgage, Inc PRESORT PO Box 9090 First -Class Mail Temecula, CA 92589 -9090 U.S. Postage and Fees Paid W SO 7196 90069295 8745 7866 Send Payments to: CitiMotgage, Inc PO Box 689196 Des Moines, IA 50368 -9196 20120323 -168 AMY R BOBB 15 ROUND HILL RD Send Correspondence to: CAMP HILL, PA 17011 -2636 CitiMortgage, Inc 6400 Las Colinas Blvd. Irving, TX 75063 - 0 CITIPAACT6 t CitiMortgage citi www.citimortgage.com 03/23/2012 AMY R BOBB 15 ROUND HILL RD CAMP HILL, PA 17011 -2636 RE: Property: 15 ROUND HILL ROAD CAMP HILL, PA 17011 Loan No.. Mortgagee: CitiMortgage, Inc. NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of PA Act No. 6 of 1974. (READ ALL PAGES OF THIS NOTICE CAREFULLY) Dear CitiMortgage Customer(s): If you have filed bankruptcy, CitiMortgage is providing this notice to you for compliance and informational purposes as lender or servicing agent for the lender and is not attempting to collect a debt from you (deficiency or otherwise) or in any way violate the provisions of the United States Bankruptcy Code. The MORTGAGE held by CitiMortgage, Inc. (hereinafter we, us or ours) on your property located at the above noted property address, IS IN SERIOUS DEFAULT, because you have not made the monthly payments as noted below under (a). Late -and other charges have also accrued to this date in the amount noted below under (b and c). Unapplied Funds received (if applicable) reflect under (d). The total amount now required to cure this default, as of the date of this letter, is noted below under (e). (a) 01/01/12 thru 03/01 /12 ' 3 @ $1,570.09 /month 3 @ $49.76/late charge/month $4,859.55 (b) Previous late charge(s) $86.02 (c) Delinquency Expense(s) $94.50 (d) Unapplied Funds $ (e)TOTAL AMOUNT (a)+(b)+(c)t(d) REQUIRED AS OF THIS DATE: $5,040.07 You may cure this default by April - 27, 2012 (or the next business day thereafter if April 27, 2012 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (d) above. Any additional payments and late charges that fall due during this period must also be paid to bring your loan current. Please submit payment to the following address: CitiMortgage, Inc. Loan Payments P.O. Box 689196 Des Moines, IA 50368 -9196 © 2011 CitiMortgage, Inc. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. CitiMortgage, Inc is an equal housing lender. Citi, Arc Design, and Citi and Arc IN Design are registered service marks of Citigroup Inc. 'Calls are randomly monitored and recorded for quality assurance. CitiMortgage is a debt collector and any information obtained will be used for that purpose. CITIPAACT6 7196 9006 9295 8745 7866 Page t of 3 If you do not cure the default by April 27, 2012, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by April 27, 2012, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default by April 27, 2012, you will not be required to pay attorney's fees. Also, we may sue you personally for the unpaid principal balance, and all other sums due under the mortgage. If you have not cured the default by April 27, 2012, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately THREE (3) MONTHS FROMIHE DATE OF THIS LETTER. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (800).723 - 7906 *. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have the right to reinstate after acceleration and the right to bring a court action or assert in any foreclosure proceeding, the non - existence of a default or any other defense you have to acceleration and the sale of the property. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR TO, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO.HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF, Under IRS regulation, we must report any foreclosure to the IRS on form 1099 -A. The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information. If your delinquency is a result of a loss of employment income or a reduction in employment income you may be eligible for homeownership counseling from one the Department of Housing and Urban Development ( "HUD ") approved homeownership counseling agencies. Please call us at (800) 723 -7906* for information regarding the HUD - approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our Loan Counselors. CITIPAACT6 7196 9006 9295 8745 7866 Page 2 of 3 r If you cure the default, the mortgage will be restored to .the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, Collection Department CitiMortgage, Inc. *CALLS ARE RANDOMLY MONITORED AND RECORDED TO ENSURE QUALITY SERVICE. This is an attempt to collect a debt, and any information obtained will be used for that purpose. In the event you are subject to an Automatic Stay issued by a United States Bankruptcy Court or the referenced debt has been discharged in Bankruptcy, this communication is not intended to be an attempt to collect a debt. If an attorney represents you, please refer this letter to such attorney and provide us with such attorney's name, address and telephone number. t J CITIPAACT6 7196 9006 9295 8745 7866 Page 3 of 3 VERIFICATION A kIn l7. U , hereby states that he /she is employed as Vice President — Document Control of CitiMortgage, Inc., the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: O ce Pkesid en-� -- b oa &J'pz� Title: DATE: FILE #: 12 -0776 NAME: BOBB, CHARLES L., LYNNEA D., NATHANIEL C. & AMY R. • n LFD 0FFICP POWERS, KIRN & JAVARDIAN, LLC ?r's ;, S 0 Z' 0 1 Gregory Javardian, Esquire Id No. 55669 -' Jill Manuel - Coughlin, Esquire Id No. 6325 ?j'1F "E �1 ;� D COUNTY Mary F. Kennedy, Esquire Id No. 77149j� k� G' F Meghan K. Boyle, Esquire Id No. 201661 Sean P. Mays, Esquire Id No. 307518 Richard J. Nalbandian,111, Esquire Id No. 312653 1310 Industrial Boulevard, Suite 101 Southampton, PA 18966 (215) 942 -2090 ATTORNEYS FOR PLAINTIFF CITIMORTGAGE, INC. COURT OF COMMON PLEAS 1000 TECHNOLOGY DRIVE O'FALLON, MO 63368 CIVIL DIVISION PLAINTIFF CUMBERLAND COUNTY VS. NO. I g "' CHARLES L. BOBB COMPLAINT IN LYNNEA D. BOBB MORTGAGE FORECLOSURE NATHANIEL C. BOBB AMY R. BOBB 15 ROUND HILL ROAD CAMP HILL, PA 17011 DEFENDANTS NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action you may be able to participate in a court supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First within twenty 20 days of your receipt of this notice you must contact MidPenn Legal Services at 717 2439400 extension 2510 or 800 8225288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative you must promptly meet with that legal representative within twenty 20 days of the appointment date. During that meeting you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto the legal representative will prepare and file a Request for Conciliation Conference with the Court which must be filed with the Court within sixty 60 days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. r Y If you are represented by a lawyer you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty 60 days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME YOU MUST ACT QUICKLY AND TAKE THESTEPS REQUIRED BY THIS NOTICE THIS PROGRAM IS FREE. Dat Re!pqc tfully submitted, ❑ regory Javardian, Esquire Id. No. 55669 Will Manuel- Coughlin, Esquire Id. No. 63252 ❑ Mary F. Kennedy, Esquire Id. No. 77149 ❑Meghan K. Boyle, Esquire Id. No. 201661 ❑Sean P. Mays, Esquire Id. No. 307518 ❑Richard J. Nalbandian, III, Esquire Id. No. 312653 Attorneys for Plaintiff r Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge CUSTOMER/ PRIMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name Realtor Phone Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different) City State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: Number of people in household How long: CO- BORROWER Mailing Address: City: State Zip: Phone Numbers: Home: Office: Cell: Other: Email: Number of people in household How long: FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number Date You Closed Your Loan: Second Mortgage Lender: Type of Loan Loan Number Total Mortgage Payments Amount: $ Included Taxes Insurance:$ Date of Last Payment: Primary Reason for default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes provide names, location of court, case number & attorney Assets Amount Owed: Value: Home: $ $ Other Real Estate $ $ Retirement Funds $ $ Investments $ $ Checking $ $ Savings $ $ Other $ $ Automobile #1: Model Year: Amount owed: $ Value: Automobile #2: Model Year: Amount owed $ Value: Other transportation (automobiles boats motorcycles Model) Model: Year: Amount owed $: Value: $ r MONTHLY INCOME Name of Employers 1. 2. 3. Additional Income Description (not wages): 1. monthly amount $ 2. monthly amount $ Borrower Pay Days: Co- Borrower Pay Days MONTHLY EXPENSES (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage $ Food $ 2nd Mortgage $ Utilities $ Car Payment(s) $ Condo/Neigh. Fees $ Auto Insurance $ Med not covered $ Auto fuel/repairs $ Other prop payment $ Install Loan Payment $ Cable TV $ Child Support/Alimony $ Spending Money $ Day /Child Care Tuition $ Other Expenses $ Amount Available for Monthly Mortgage Payments Based on Income Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes please provide the following information Counseling Agency: Counselor: Phone Office: Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance Yes ❑ No ❑ If yes please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency Yes ❑ No ❑ If yes please indicate the status of those negotiations: Please provide the following information if known regarding your lender's or lender loan servicing company Lender Contact (Name) Phone Servicing Company (Name) Contact: Phone AUTHORIZATION I /We authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /We understand that I /we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and Gregory Javardian, Esquire, lender counsel: Proof of income Bank statements to cover the last 60 day period If self employed, we must have the last 3 bank statements from both their business and personal bank accounts. Proof of any expected income for the last 45 days Dodd Frank Certificate 4506T -EZ form Copy of last two months utility bill Letter explaining reason for delinquency and any supporting documentation Hardship letter Listing agreement if property is currently on the market Gregory Javardian, Esquire 1310 Industrial Boulevard 2 " Floor, Suite 202 Southampton, PA 18966 (tel) 215- 942 -2090 (fax) 215- 942 -8661 Attention: Deirdre Cranston (tel) 215- 942 -2090 ext. 1414 deirdre.cranston@pkilic.com SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 4 (_ Sheriff Jody S Smith Chief Deputy ' Richard W Stewart Solicitor CITIMORTGAGE, Inc. Case Number vs. Charles L. Bobb (et al.) 2013-5606 SHERIFF'S RETURN OF SERVICE 09/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Charles L. Bobb, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 09/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lynnea D Bobb, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 09/27/2013 03:20 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit:Amy Bobb at 15 Round Hill Road, East Pennsboro, Camp Hill, PA 17011. TEPHEN BENDER, DEPUTY 09/27/2013 03:20 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be AMY BOBB WIFE,who accepted as"Adult Person in Charge"for Nathaniel C Bobb at 15 Round Hill Road, East Pennsboro, Cam Hill, PA 17011. - STEPHEN BENDER, DEPUTY 09/30/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Charles L. Bobb, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 15 Round Hill Road, East Pennsboro, Camp Hill, PA 17011. Deputies were advised that the defendant resides at 245 Birdie Lane, Etters, PA 17319. 09/30/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lynnea D Bobb, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 15 Round Hill Road, East Pennsboro, Camp Hill, PA 17011. Deputies were advised that the defendant resides at 245 Birdie Lane, Etters, PA 17319. 10/09/2013 12:56 PM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Charles Bobb,who accepted for Lynnea D Bobb, at 245 Birdie Lane, Etters, PA 17319. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. ,unry.a, .hent' iE se*i 10/09/2013 12:56 PM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Charles L. Bobb, personally, at 245 Birdie Lane, Etters, PA 17319. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $158.41 SO ANSWERS, October 25, 2013 RbNIV R ANDERSON, SHERIFF SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber + PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy,Administration CITIMORTGAGE, INC. vs. Case Number CHARLES L. BOBB (et al.) 13-5606 CIVIL SHERIFF'S RETURN OF SERVICE 10/09/2013 12:56 PM - DEPUTY TODD STAHL, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT,TO WIT: CHARLES L. BOBB AT 245 BIRDIE LANE, ETTERS, PA 17319. X t, -�.'XL TO L!%,SlIT711L, DEPUTY 10/09/2013 12:56 PM - DEPUTY TODD STAHL, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE CHARLES BOBB, SPOUSE, WHO ACCEPTED AS"ADULT PERSON IN CHARGE" FOR LYNNEA D. BOBB AT 245 BIRDIE LANE, ETTERS, PA 17319. Xki ` �,. O D S17A,H L, DEPUTY SHERIFF COST: $49.08 SO - October 22, 2013 RICHARD P KEUERL"EfIER, SHERIFF 0NN(3NW1L1 M OF=SheilaE. NNS1`LVANIA Seal Notary public ork County Ires Feb.1,2017 , ENNSYLVANIAAS90CT,"10,0 ARtE5 NOTARY Affirmed and subscribed to before me this 22ND day of OCTOBER 2013 (c)CauntySuite Sheriff.Teleosnft-l,,.c MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR DEFENDANTS Bangs Law Office, LLC NATHANIEL C. BOBB and 429 South 18t Street AMY R. BOBB • Camp Hill, PA 17011 (717) 730-7310 Supreme Court ID #41263 CITIMORTGAGE, INC. ) IN THE COURT OF COMMON LEAS Plaintiff ) OF CUMBERLAND COUNT PENNSYLVANIA ,'', ' vs. ) ter' 24 NO. 13-5606 CIVIL CHARLES L. BOBB ) LYNNEA D. BOBB ) MORTGAGE FORECLOSUR .za. NATHANIEL C. BOBB ) AMY R. BOBB ) Defendants ) REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendants Charles L. Bobb, Lynnea D. Boob, Nathaniel C. Bobb and Amy R. Bobb are the owners of the real property located at 15 Round Hill Road, Camp Hill, Pennsylvania, which is the subject of this mortgage foreclosure action; 2. Defendants Nathaniel C. Bobb and Amy R. Bobb live in the subject real property, which is their primary residence; 3. Defendants Nathaniel C. Bobb and Amy R. Bobb have been served with a"Notice of Residential Mortgage Foreclosure Diversion Program" and have taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. We understand that false statements are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Signature of Defend s Counsel/Appointed Legal Date Representative /22 ., / 41/4 //// f Nathaniel C. Bobb Date ---- _ 1144113____– — Amy R. Bob Date MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR DEFENDANTS Bangs Law Office, LLC NATHANIEL C. BOBB and 429 South 18th Street AMY R. BOBB Camp Hill, PA 17011 (717) 730-7310 Supreme Court ID #41263 CITIMORTGAGE, INC. ) IN-THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) NO. 13-5606 CIVIL c.) _ CHARLES L. BOBB ) LYNNEA D. BOBB ; MORTGAGE FORECLOSURE. 17c) NATHANIEL C. BOBB ) AMY R. BOBB ) Defendants ) CASE MANAGEMENT ORDER AND NOW this obn0( - day of _ '4 j � / , 2013, Defendants Nathaniel C. Bobb and Amy R. Bobb/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that they have complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby Ordered and Decreed that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation conference on ,2-0/g at 3 i 0 0 /) .M. in U1/47t1.AP!l4 # _ at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the de c:,dantihorr. er must serve upon the nta,rt;ff/tender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference,the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled Conciliation Conference. BY THE COURT, J. P eis Lam, AJ 1^2.1.t.) - j cgs /A:1%113 MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR DEFENDANTS Bangs Law Office, LLC NATHANIEL C. BOBB and 429 South 18th Street AMY R. BOBB Camp Hill, PA 17011 (717) 730-7310 Supreme Court ID #41263 CITIMORTGAGE, INC. ) IN THE COURT OF COMMON(PLEAS Plaintiff ) OF CUMBERLAND COUNT= PENNSYLVANIA rri .rn f'� Vs. ) s, ) NO. 13-5606 CIVIL cri ?' CHARLES L. BOBS r , LYNNEA D. BOBB ) MORTGAGE FORECLOSURE c, NATHANIEL C. BOBB ) ' AMY R. BOBB ) f Defendants ) REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendants Charles L. Bobb, Lynnea D. Boob, Nathaniel C. Bobb and Amy R. Bobb are the owners of the real property located at 15 Round Hill Road, Camp Hill, Pennsylvania, which is the subject of this mortgage foreclosure action; 2. Defendants Nathaniel C. Bobb and Amy R. Bobb live in the subject real property, which is their primary residence; 3. Defendants Nathaniel C. Bobb and Amy R. Bobb have been served with a"Notice of Residential Mortgage Foreclosure Diversion Program" and have taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and eorr cct. Wc. understand that false statements are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. A41.2/tt k Signature of Defend. Is Counsel/Appointed Legal Date Representative rfi `/ Nathaniel C. Bobb Date Amy R. Bob Date CITIMORTGAGE, INC•, • IN THE COURT OF COMMON PLEAS OF • Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA • vs. • CIVIL ACTION—LAW • NO. 13-5606 CIVIL CHARLES L. BOBB, LYNNEA D. : BOBB, AND NATHANIEL C. • BOBB, • Defendants . MORTGAGE FORECLOSURE ORDER AND NOW, this /0 day of January, 2014, at the request of counsel for the parties, the conciliation conference set for January 10, 2014, is continued to Friday, February 21, 2014, at 9:30 a.m. in Chambers of the undersigned. BY THE COURT, Kevin • . Hess, P. J. C= eon Haller, Esquire rr' For the Plaintiff ichael L. Bangs, Esquire `-- For the Defendants =' oft / /v /11 CITIMORTGAGE, INC., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA vs. : CIVIL ACTION—LAW : NO. 13-5606 CIVIL CHARLES L. BOBB, LYNNEA D. : BOBB, AND NATHANIEL C. BOBB, Defendants : MORTGAGE FORECLOSURE ORDER AND NOW,this Z o" day of February, 2014, at the request of counsel for the parties,the conciliation conference set for February 21, 2014, is continued to Friday,April 25, 2014, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, `, - A 41/4-.. Kevin • vHess,P. J. ✓Leon Haller, Esquire For the Plaintiff . Michael L. Bangs, Esquire For the Defendants :rim 0.--Op l'ES' 0/1--UlfEL- afr P x a, . 4 - zr' r\) CITIMORTGAGE, INC., : IN THE COURT OF COMMON PLEAS OF Plaintiff VS. CHARLES L. BOBB, LYNNEA D. BOBB, AND NATHANIEL C. BOBB, Defendants : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW NO. 13-5606 CIVIL : MORTGAGE FORECLOSURE ORDER AND NOW, this -2 day of April, 2014, on agreement of the parties, the conciliation conference herein is continued generally. BY THE COURT, Pekalska, Esquire Powers Kirn & Javadian 1310 Industrial Blvd., Suite 101 Southampton, PA 18966 ./1,eon Haller, Esquire For the Plaintiff ....,,/Michael L. Bangs, Esquire For the Defendants :rlm is 02. q/I y LcL #12-0776 POWERS KIRN & ASSOCIATES, LLC JILL MANUEL-COUGHLIN, .ESQUIRE Id. No. 63252 JOLANTA PEKALSKA, ESQUIRE Id. No. 307968 HARRY B. REESE, ESQUIRE Id. No. 310501 DANIEL C. FANASELLE, ESQUIRE Id. No. 312292 MATTHEW J. MCDONNELL, ESQUIRE Id. No. 313549 EIGHT NESHAMINY INTERPLEX, SUITE 215 TREVOSE, PA 19053 (215) 942-2090 CitiMortgage, Inc. Plaintiff vs. Nathaniel C. Bobb Amy Bobb Charles L. Bobb Lynnea D. Bobb COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 13-5606 Defendant(s) PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above case DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs. Dated: o J Manuel-Coughli , Esquire Id. No. 63252 ❑ J anta Pekalska, Esquire Id. No. 307968 arry B. Reese, Esquire Id. No. 310501 ❑ Daniel C. Fanaselle, Esquire Id. No. 312292 o Matthew J. McDonnell, Esquire Id. No. 313549 Attorneys for Plaintiff #12-0776 POWERS KIRN & ASSOCIATES, LLC JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252 JOLANTA PEKALSKA, ESQUIRE Id. No. 307968 HARRY B. REESE, ESQUIRE Id. No. 310501 DANIEL C. FANASELLE, ESQUIRE Id. No. 312292 MATTHEW J. MCDONNELL, ESQUIRE Id. No. 313549 EIGHT NESHAMINY INTERPLEX, SUITE 215 TREVOSE, PA 19053 (215) 942-2090 CitiMortgage, Inc. COURT OF COMMON PLEAS Plaintiff vs. Nathaniel C. Bobb Amy Bobb Charles L. Bobb Lynnea D. Bobb CIVIL DIVISION CUMBERLAND COUNTY No. 13-5606 Defendant(s) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Praecipe to Discontinue Without Prejudice was sent by first class mail, postage pre -paid, upon the following on the date listed below: Nathaniel C. Bobb 15 Round Hill Road Camp Hill, PA 17011-2636 Charles L. Bobb 15 Round Hill Road Camp Hill, PA 17011-2636 Dated: kb `27 Amy Bobb 15 Round Hill Road Camp Hill, PA 17011-2636 Lynnea D. Bobb 15 Round Hill Road Camp Hill, PA 17011-2636 1 Manuel-Coughli , Esquire Id. No. 63252 Jolanta Pekalska, squire Id. No. 307968 ❑ Harry B. Reese, Esquire Id. No. 310501 ❑ Daniel C. Fanaselle, Esquire Id. No. 312292 ❑ Matthew J. McDonnell, Esquire Id. No. 313549 Attorneys for Plaintiff